ID: nht71-2.32

DATE: 04/28/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Simek Manufacturing Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 7, 1971, concerning the applicability of the Tire identification and Record Keeping Regulations to boat trailers. As used in the regulation, "Motor Vehicle" includes boat trailers as well as other types of trailers. Thus, the regulation does apply to boat trailers.

If a trailer is shipped with the tires attached, section 574.10 requires the motor vehicle manufacturer to maintain the records of the name and address of the first purchaser for purposes other than resale because the tires will be "on or in" a vehicle shipped by him. If, however, the trailers are shipped in a "knocked down" configuration with the tires shipped seperately, the tires are not considered to be shipped "on or in" the vehicle within the meaning of Section 574.10, and therefore, the vehicle dealer is, by section 57 required to report the name and address of the purchaser to the tire manufacturer.

The manner of maintaining the records is not specified by the regulation and any method that satisfies the requirements of the regulation may be used.

ID: nht71-2.33

DATE: 04/29/71

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Ashimori Industry Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 1, 1971, regarding self-fastening seat belt systems.

Any system which requires no action by vehicle occupants can be used to meet the appropriate options of Federal Motor Vehicle Safety Standard No. 208 - Occupant Crash Protection. "The action," in this case, means that no action is permitted by vehicle occupants other than would be required if the protective system were not present in the vehicle.

We have received a number of petitions for reconsideration or clarification of Notice 9, particularly in reference to the role of a passive (no action) safety belt system as it relates to the requirements for Type 1 or Type 2 seat belt installations prior to August 15, 1975. We are now in the process of resolving the petitions received, and our final decisions in response to the petitions will be issued in the Federal Register as soon as possible.

Your interest in our motor vehicle safety programs is most appreciated.

ID: nht71-2.34

DATE: 04/29/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Busby, Rivkin, Sherman and Levy

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 20, 1971, in which you enclosed a request for clarification, on behalf of Rolls-Royce, Ltd., of the requirements of Standard No. 208, Occupant Crash Protection. Essentially, the question was whether a "European type combined lap and diagonal strap seat belt assembly with retractor" could be furnished instead of the "Type 1 seatbelt assembly" specified in the second protection option on passenger cars manufactured from August 15, 1973, to August 14, 1975.

Standard No. 208 does not permit this substitution. The key feature of the second option in the August 1973- August 1975 period is that the manufacturer must design his vehicles so that the front seat occupants are protected from injury when restrained with lap belts only, and provide lap belts for all occupants that may, at least, be separately usable as such. A detachable upper torso belt may be provided at the manufacturer's option. The basis for this requirement is the well-documented finding that a much larger percentage of the American public will fasten lap belts than will use upper torso belts, whether the latter are of the detachable or the combination type.

We are pleased to be of assistance.

ID: nht71-2.35

DATE: 04/30/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Hamill Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 16, 1971, in which you ask certain questions concerning a child booster seat that you plan to market. You describe the booster seat as a rectangle about 6 inches in height, tapering to 4 inches in the front, and state that it would be advertised for use by children under 50 pounds and would not be designed to fall into the category of child seating systems under Standard No. 213. You also state that your engineers feel a booster chair will "definitely help more five, six and seven year old children to use seat belts simply because these children will be able to see out of a vehicle."

While you state that the booster seat "would not be designed to fall into the category of child seating systems under Standard No. 213," it is not clear from your description of the device that this is actually the case. If you wish an opinion on this matter, we will provide one, but to do so we will need some additional information. Specifically, we will need to know if the booster seat is to be designed or advertised for use with the vehicle seat belts, and if so, how it will be so designed or advertised.

The questions you ask concerning the booster seat are: (1) Can we set a minimum of 50 or 60 pounds? (2) Exactly what is the maximum child weight covered under MVSS #213? and (3) What recommended weight can we advertise as a minimum for our booster seat?

The answers to these questions do not depend on whether the standard applies to your booster seat. If the device is a child seating system, Standard No. 213 does not specify the minimum or maximum heights or weights for children who may use it. Under the standard, it is up to the manufacturer to determine, based upon the design of each particular child seating system, the heights and weights of children for which he recommends the child seating system.

If the device is not a child seating system, the manufacturer is not required to recommend any heights or weights for children who can use it. Should he choose to do so, however, the heights and weights recommended must be consistent with the safe use of the device.

ID: nht71-2.36

DATE: 04/30/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Hartman Mfg. Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 9, 1971 concerning certain provisions of Motor Vehicle Safety Standard No. 213, "Child Seating Systems." In your letter you ask whether S4.4 of the standard requires the child seating system itself to be restrained by the seat belt assembly. You state that S4.5.1 indicates to you that the vehicle seat belt assembly is employed to restrain both the child and the seating system, and request that this issue be clarified.

S4.4(a) of the standard requires each child seating system, when installed as the manufacturer directs, to be restrained by the vehicle seat belt assembly. The vehicle seat belt assembly may also be used to directly restrain the child, but it is not required to do so. When it is used for this purpose, however, it must distribute the restraint forces as specified by S4.5.1 of the standard.

The statement in the preamble of the notice of March 23, 1970 to which you refer describes the scope of the standard. This statement means that any device for seating children in a motor vehicle that is designed to utilize the vehicle restraint system or provides restraint by itself, or both, is a "child seating system" and must comply with all the requirements of the standard.

We are pleased to be of assistance.

ID: nht71-2.37

DATE: 04/30/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Recreational Vehicle Institute

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 8, 1971, requesting a confirmation of your understanding as to two sections of Standard No. 208, Occupant Crash Protection.

You are correct in reading section S4.3 to provide options for trucks and multipurpose passenger vehicles of more than 10,000 pounds GVWR that differ from the options provided under S4.2 for trucks and multipurpose passenger vehicles with a GVWR of 10,000 pounds or less.

You are also correct in reading S4.2.2 and S4.2.3 to mean "chassis-mount camper" when the term "vehicles carrying chassis-mount campers" is used.

The petitions filed by RVI requesting amendments to Standards No. 208 and 210 are under active consideration and you should expect to receive an answer in the very near future.

ID: nht71-2.38

DATE: 05/03/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Darden; Neef & Heitson

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 20, 1971, petitioning for rulemaking pursuant to 49 CFR 553.31, asking that the Tire Identification and Record Keeping Regulation be inapplicable to mobile homes. The points raised in your petition have been thoroughly considered, however, your petition, by copy of this letter, is denied. As you know, many of the points you raised were considered in connection with the interpretation of "Motor Vehicle" as it refers to trailers, issued March 31, 1970 (35 F.R. 5333) (Copy Enclose The interpretation concluded that a mobile home is a motor vehicle within the meaning of the National Traffic and Motor Vehicle Safety Act of 1966, (15 U.S.C. 1381 et seq.). As such, mobile home manufacturer are required to comply with the requirements of Part 574.

The burden placed on the mobile home manufacturer by the regulation does notaappear unreasonable. The regulation requires that the vehicle manufacturer or his designs maintain a record of the tires shipped on or in its vehicles and maintain the names and addresses of the purchasers of its vehicles. Locating the purchaser should be a comparatively easy task.

Mobile homes are constructed with a view, of course, to their over-the-road capabilities. The Tire Identification and Record Keeping Regulation should be applicable to mobile homes since it relates directly to one of the instrumentalities for moving a mobile home. Should a tire sold with a mobile home be defective, we consider it essential that the purchaser of the vehicle be notified of this fact.

ID: nht71-2.39

DATE: 05/04/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 12, 1971, regarding the March 10, 1971, amendment to Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection.

The following are answers to your questions:

1. Question:

Standard to be effective as of August 15, 1973, through August 14, 1975, second option (S4.1.2.2) --- How many dummies should be used for frontal crash? Is the use of dummies necessary for roar and front seats or for front seat only?

Answer:

S4.1.2.2 (b) and (c) specify that the frontal barrier crash requirements of S5.1 shall be met for each front designated seating position. Thus, a dummy must be placed in each front designated seating position for these tests.

2. Question:

Same standard (S4.1.2) --- For a two seater car, what options for passive seat belts for both occupants should be taken? (First or Second option or one of these)

Answer:

A passive belt system may be used to meet the requirements of either the first or the second option under S4.1.2. If the passive belt system is intended to get the second option, however, it must employ a Type 1 seat belt assembly either as a part of the passive belt or as a separate component. This Type 1 belt must be separately usable, and must in addition meet the requirements of S7.1 and S7.2 and have a seat belt warning system.

The risk that the presence of a latch in the system may cause occupants to leave the belt unfastened while the vehicle is in motion is of concern to the NHTSA. At the same time, it is evident that some method of release is necessary for passive belt systems as well as for other passive restraints. We are therefore considering additional rulemaking on the subject of passive belts.

3. Question:

In regard to the Volkswagen Mini bus, which is the category of this automobile? (Multipurpose Passenger or Passenger)

Answer: It in a multipurpose passenger vehicle.

4. Question:

I understand that the convertible type automobile has partial exemption before August 15, 1973. What exception would be taken after that date? Also, through rumor, I have heard that this automobile will be included in the Multipurpose Passenger Car category. Is the correct?

Answer:

Because the multipurpose passenger vehicle may be manufactured in convertible form, the standard refers to convertibles under the multipurpose passenger vehicle requirements. A clear distinction is intended between such convertible multipurpose passenger vehicles, which are regulated by S4.2, and convertible passenger cars, which are regulated by S4.1. There is no plan to treat a convertible passenger car as a multipurpose passenger vehicle.

Convertible passenger cars are not distinguished from other passenger cars other than to exempt them from shoulder belt requirements in the January 1, 1972, to August 14, 1973, time period. They must thereafter meet the passive system requirements applicable to passenger cars, with no special exceptions.(Illegible Word) the multipurpose passenger vehicle category, convertibles are given the option of meeting lesser passive requirements than other multipurpose passenger vehicles (S4.2.2 and S4.2.3).

Please advise us if further clarification is needed.

ID: nht71-2.4

DATE: 02/10/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Seiberling Tire & Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 28, 1971, to Mr. Diag concerning Part 574 - Tire Identification and Record Keeping regulations and to confirm that the fourth grouping, data code, may be placed at the end of the tire identification number by means of a separate serial tin and be separated from the third grouping by a space which will not exceed 3/4 of an inch.

ID: nht71-2.40

DATE: 05/05/71

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 1, 1971, requesting our interpretation of the term "provision" as used in the definition of seat belt assembly anchorage in Standard No. 210 (35 F.R. 18116, November 26, 1970).

The change from the use of the word "device" in the prior issuance of the rule (35 F.R. 15293) to the use of "provision" in the November 26 issuance was made to avoid any appearance of requiring a specific type of structure.

A hole capable of accepting a seat belt assembly's attaching hardware would therefore qualify as an anchorage. It would not, of course, be an anchorage conforming to Standard No. 210 unless it could also withstand the forces specified in that standard.

Please advise us if you have further questions on this matter.